Personal data processing policy
AQUA TOUR TRAVEL
Company name: Elite International SAS – Aqua Tour Travel
NIT: 901.469.590
Home: Bogotá DC, Colombia
Email: reservas@aquatourtravel.com
Activity: Travel agency and tourist services
Date of adoption: October 1, 2026
Version: 1.0
1. OBJECT
The purpose of this Personal Data Processing Policy is to establish the criteria, procedures and conditions under which Elite International SAS – Aqua Tour Travel, henceforth “Aqua Tour Travel”, collects, stores, uses, retains, updates, consults, circulates and, where appropriate, deletes the personal data of its customers, potential customers, travelers, users, suppliers, partners and other data subjects.
Aqua Tour Travel recognizes the constitutional right of all persons to know, update, rectify and control the processing of personal information held in its databases, in accordance with the Political Constitution of Colombia, the Law 1581 of 2012, he Decree 1377 of 2013, the rules that modify, add to or replace them and other applicable provisions.
2. DATA CONTROLLER
The entity responsible for processing personal data is:
ELITE INTERNATIONAL SAS – AQUA TOUR TRAVEL
NIT: 901.469.590
City: Bogotá DC, Colombia
Email: reservas@aquatourtravel.com
For the purposes of exercising the rights of the holders, Aqua Tour Travel will have the channels established in this Policy.
3. SCOPE
This Policy applies to personal data collected by Aqua Tour Travel through any of its customer service and marketing channels, including, but not limited to:
- WhatsApp.
- Telephone calls.
- Email.
- Web page.
- Social networks.
- Physical or digital forms.
- Quotes.
- Reservations.
- Technological platforms used by Aqua Tour Travel.
- In-person service.
- Events and business activities.
- Advertising campaigns.
- Databases from commercial alliances, when their processing is legitimate and the corresponding authorizations are obtained.
4. PERSONAL DATA THAT MAY BE COLLECTED
Depending on the service requested and the needs of the tour operation, Aqua Tour Travel may collect information such as:
4.1. Identification data
- First and last names.
- Type and number of identity document.
- Birthdate.
- Nationality.
- Country of residence.
- Information needed to identify the traveler.
4.2. Contact details
- Phone number.
- WhatsApp number.
- Email.
- Residential address, when necessary for the provision of the service.
- Emergency contact information, when required and authorized.
4.3. Travel-related information
- Destination.
- Travel dates.
- Number of travelers.
- Accommodation preferences.
- Information related to flights, hotels, transfers, excursions and other tourist services.
- Information needed to issue tickets, make reservations or provide tourist services.
4.4. Documents
When necessary for the provision of the service, documents such as the following may be requested and processed:
- National identity card.
- Passport.
- Visa.
- Travel permits.
- Immigration documents.
- Documents required by airlines, hotels, tour operators, immigration authorities or other providers related to the contracted service.
These documents will be used only for the purposes informed to the owner and necessary for the management of the corresponding service.
5. SENSITIVE DATA
Aqua Tour Travel acknowledges that certain data may be considered sensitive data in accordance with Colombian legislation.
In certain tourist services it may be necessary to know information related to, for example, health conditions, medical assistance, special requirements, disability, diet for medical reasons or other particular circumstances of the traveler.
When it is legally necessary to obtain this type of information:
- The data subject will be informed that this is sensitive information.
- The specific purpose of the treatment will be indicated.
- Express authorization will be requested where appropriate.
- The data subject may refrain from authorizing the processing of sensitive data, unless there is an applicable legal exception.
- Aqua Tour Travel will limit the processing to what is strictly necessary for the authorized purpose.
Law 1581 establishes special rules for the processing of sensitive data and requires explicit authorization when appropriate.
6. PURPOSES OF THE PROCESSING
Personal data may be processed by Aqua Tour Travel for the following purposes:
A. Attention and advice
- Attend to requests made by clients and potential clients.
- Provide tourist advice.
- Respond to requests received via WhatsApp, phone, email, social media, and other channels.
- Prepare quotes.
- Follow up on business requests.
B. Reservations and provision of services
- Manage bookings for flights, hotels, tour packages, cruises, transfers, excursions, car rentals and other services.
- Issue tickets, vouchers, coupons, confirmations and documents related to the contracted services.
- Coordinate itineraries.
- Manage changes, cancellations, refunds, and modifications.
- Provide support before, during and after the trip.
C. Contractual and legal compliance
- Execute contracts and service orders.
- Fulfill legal obligations.
- Attend to requests from competent authorities.
- Manage accounting, administrative and financial processes.
- To handle complaints, requests and processes related to the provision of the service.
D. Management with tourism providers
When necessary to provide the contracted service, Aqua Tour Travel may provide information to airlines, hotels, tour operators, carriers, insurers, assistance companies, booking platforms and other suppliers directly involved in providing the service.
The supply will be limited to the information necessary to fulfill the corresponding purpose and will be carried out in accordance with the applicable legal authorizations and conditions.
E. Commercial Management
When authorized by the data subject and legally permissible, the data may be used for:
- Inform about promotions.
- Send marketing campaigns.
- Communicate new destinations.
- Submit bids.
- Inform about loyalty programs.
- Send information about Aqua Tour Travel products and services.
The data subject may request at any time that their data not be used for direct marketing purposes, in accordance with the mechanisms established by Aqua Tour Travel.
7. PROCESSING OF DATA OF POTENTIAL CLIENTS
When a person contacts Aqua Tour Travel requesting information, advice or a quote, their data may be processed for:
- Identify the applicant.
- Respond to your request.
- Prepare and send quotes.
- Perform sales follow-up.
- Manage the travel request.
- Inform about alternatives related to the application.
Receiving an inquiry does not imply that the person is obligated to contract any service.
8. AUTHORIZATION OF THE HOLDER
Aqua Tour Travel will request the prior, express and informed authorization of the owner when required by applicable legislation.
The authorization may be obtained by physical, electronic, digital, telephone or other means that allow its existence to be subsequently verified.
The authorization must allow proof that the holder was aware:
- What data will be processed.
- What will they be used for?.
- Who is responsible?.
- Your rights.
- The available channels to exercise them.
Law 1581 defines authorization as the prior, express and informed consent of the holder and establishes, as a general rule, the need for authorization for processing, except for the exceptions provided by law.
9. PROCESSING OF DATA OBTAINED THROUGH WHATSAPP
When a customer or potential customer voluntarily contacts Aqua Tour Travel via WhatsApp, the data provided may be used to handle the request, provide quotes, manage bookings, and deliver the requested services.
Aqua Tour Travel must inform the data subject about the processing of their data and, where appropriate, obtain the respective authorization.
Information received via WhatsApp must be handled exclusively by authorized personnel and for permitted purposes.
10. USE OF TRAVEL DOCUMENTS
The documents provided by travelers, including passports, identity documents, visas and other required supporting documents, will be processed exclusively for the purposes related to:
- Price.
- Booking.
- Emission.
- Confirmation.
- Provision of service.
- Compliance with supplier or authority requirements.
- Handling changes, cancellations or refunds.
Aqua Tour Travel will not use these documents for purposes other than those informed and authorized, unless there is a legal obligation that allows or requires other treatment.
11. SUPPLY TO SUPPLIERS AND THIRD PARTIES
In order to properly provide the contracted tourist services, Aqua Tour Travel may share the strictly necessary data with third parties involved in the operation.
Among them you will find:
- Airlines.
- Hotels.
- Tour operators.
- Incoming agencies.
- Transport companies.
- Travel medical assistance companies.
- Insurance companies.
- Car rental companies.
- Booking platforms.
- Technology providers.
- Companies in charge of services contracted by the client.
- Competent authorities where applicable.
When the service involves providers located outside of Colombia, international transfers or transmissions of information may occur, which must comply with the conditions established by applicable Colombian legislation.
12. CONFIDENTIALITY
Aqua Tour Travel will take measures to ensure the confidentiality of personal data.
Employees, contractors, consultants, and other individuals with authorized access to personal information must use it only for their assigned functions and maintain confidentiality regarding the information.
This obligation will continue even after the employment, contractual or commercial relationship ends.
Law 1581 expressly contemplates the principles of security and confidentiality in the processing of personal data.
13. INFORMATION SECURITY
Aqua Tour Travel will implement reasonable and appropriate technical, human, and administrative measures to protect information against:
- Loss.
- Unauthorized access.
- Disturbance.
- Misuse.
- Unauthorized disclosure.
- Unauthorized copying or extraction.
- Accidental or unlawful destruction.
Access to information should be limited to staff and suppliers who require it for the performance of their duties or the provision of services.
14. RIGHTS OF THE DATA SUBJECTS
According to Colombian law, the holder has the right to:
- To know what personal data Aqua Tour Travel has about him.
- Request an update to your information.
- Request the correction of incorrect, incomplete, or inaccurate information.
- Request information about the use of your data.
- Request proof of the authorization granted, when applicable.
- Submit inquiries and complaints.
- Request the deletion of your data when appropriate.
- Revoke the authorization when legally possible.
- Access your personal data free of charge under the terms established by law.
- File complaints with the Superintendency of Industry and Commerce when you believe your rights have been violated.
These rights are primarily recognized in Law 1581 of 2012.
15. PROCEDURE FOR CONSULTATIONS
The data subject may request information about the personal data held in the Aqua Tour Travel databases through the available channels.
The application must allow the identification of the holder and specify the required information.
Inquiries will be handled within the terms established by current legislation.
Law 1581 establishes, as a general rule, a maximum term of ten (10) business days to answer inquiries, with the legally provided conditions for cases in which it is not possible to respond within that period.
16. COMPLAINTS PROCEDURE
The data subject who believes that the registered information should be corrected, updated, deleted, or that there is a possible breach of data protection regulations may file a complaint with Aqua Tour Travel.
The claim must contain, at a minimum:
- Identification of the holder.
- Description of the events.
- Specific request.
- Contact information.
- Documents that you consider relevant.
Aqua Tour Travel will process the claim in accordance with the terms established in current legislation.
17. CHANNEL FOR EXERCISING RIGHTS
Requests related to personal data protection may be sent to:
Aqua Tour Travel
Mail: reservas@aquatourtravel.com
City: Bogotá DC, Colombia
Helpline 3117425545
Aqua Tour Travel may establish additional channels to facilitate the exercise of the rights of the holders.
18. DATA RETENTION
Personal data will be kept for the time necessary to fulfill the purposes for which they were collected and, subsequently, for the periods required by legal, contractual, accounting, tax, administrative obligations or for the handling of possible liabilities.
The deletion of information will not be permitted when there is a legal or contractual obligation to retain it.
19. DATA ON MINORS
Aqua Tour Travel recognizes the special protection of children and adolescents.
When it is necessary to collect information from minors for the provision of a tourist service, the corresponding measures will be adopted and the special rules provided for in Colombian legislation will be observed.
Law 1581 establishes special protection for the data of children and adolescents.
20. INFORMATION UPDATE
Aqua Tour Travel may periodically request its clients to update their data in order to maintain correct, complete and current information.
Holders must endeavor to provide true, accurate and up-to-date information.
21. PROHIBITION OF UNAUTHORIZED USES
Aqua Tour Travel will not market or use the personal data of its customers for purposes other than those stated in this Policy, unless there is authorization from the owner or a legal authorization that allows such processing.
Personal information will not be publicly disclosed or made available to unauthorized third parties.
22. INTERNAL RESPONSIBILITIES
Aqua Tour Travel must ensure that its collaborators and authorized third parties:
- Access only the necessary information.
- Use the data for the authorized purposes.
- Maintain confidentiality.
- Avoid storing unnecessary information.
- Protect the documents received.
- Report security incidents.
- Follow internal data protection procedures.
23. PRIVACY NOTICE
Aqua Tour Travel may use a short privacy notice to inform the data subject, before or during the collection of information, about the existence of this Policy, its purposes and the mechanisms to consult it.
Decree 1377 of 2013 defines the privacy notice as the communication through which the data subject is informed about the existence of the processing policies, how to access them and the purposes of the processing.
24. VALIDITY
This Policy is effective from the date of its approval and will remain in effect as long as Aqua Tour Travel carries out personal data processing activities.
Any changes will be communicated through appropriate means and will be available for consultation by the owners.
25. AUTHORIZATION FOR CLIENTS AND POTENTIAL CLIENTS
For the purposes of requests made via WhatsApp, email, forms, website, social media or any other channel, Aqua Tour Travel may use the following text:
AUTHORIZATION FOR THE PROCESSING OF PERSONAL DATA
By continuing this conversation and/or voluntarily providing my personal data to Elite International SAS – Aqua Tour Travel, I authorize the processing of my personal information to address my request, provide advice, prepare quotes, manage reservations, contract and provide tourist services, follow up on my request and fulfill the obligations arising from the contracted services, in accordance with the Law 1581 of 2012, he Decree 1377 of 2013 and other applicable regulations.
I declare that I have been informed about my rights as the owner of the personal data and about the existence of the Aqua Tour Travel Personal Data Processing Policy.
☐ I authorize the sending of commercial information, promotions and news from Aqua Tour Travel.
☐ I do not authorize the sending of commercial information.
To exercise my rights of consultation, updating, rectification, deletion or revocation when applicable, I may contact reservas@aquatourtravel.com.
26. AQUA TOUR TRAVEL COMMITMENT
Aqua Tour Travel recognizes that the protection of personal data is a fundamental component of customer trust.
Therefore, it undertakes to process the information according to criteria of legality, purpose, freedom, transparency, security, restricted access and confidentiality, ensuring that the information is used exclusively for the legitimate purposes communicated to the owner.
Aqua Tour Travel
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